ACIT., CENTRAL CIRCLE-2(4), HYDERABAD vs. PRATHIMA INFRASTRUCTURE LIMITED, HYDERABAD

Facts

A search and seizure operation was conducted on Prathima Infrastructure Limited. The assessment order was passed on March 31, 2022, and the assessee contended that it was time-barred. The Revenue argued that the search concluded later due to a joint warrant with other individuals.

Held

The Tribunal held that the time limit for completing the assessment is governed by the date of conclusion of the search as recorded in the last panchanama drawn in relation to any person in whose case the warrant of authorization was issued. The Tribunal found that the last panchanama in this case was drawn on February 12, 2020, making the assessment order passed on March 31, 2022, time-barred.

Key Issues

Whether the assessment order passed under Section 153A is barred by limitation as prescribed under Section 153B, considering the conclusion date of the search conducted under a joint warrant.